CONTROLS
OVER THE
SOCIAL SECURITY ADMINISTRATION'S
TRANSIT SUBSIDY PROGRAM

September
2008

A-02-08-18050

AUDIT
REPORT

Mission

By conducting independent and objective audits, evaluations and investigations,
we inspire public confidence in the integrity and security of SSA's programs
and operations and protect them against fraud, waste and abuse. We provide timely,
useful and reliable information and advice to Administration officials, Congress
and the public.

Authority

The Inspector General Act created independent audit and investigative units,
called the Office of Inspector General (OIG). The mission of the OIG, as spelled
out in the Act, is to:

Conduct and supervise independent and objective audits and investigations
relating to agency programs and operations.
Promote economy, effectiveness, and efficiency within the agency.
Prevent and detect fraud, waste, and abuse in agency programs and operations.
Review and make recommendations regarding existing and proposed legislation
and regulations relating to agency programs and operations.
Keep the agency head and the Congress fully and currently informed of problems
in agency programs and operations.

To ensure objectivity, the IG Act empowers the IG with:

Independence to determine what reviews to perform.
Access to all information necessary for the reviews.
Authority to publish findings and recommendations based on the reviews.

Vision

We strive for continual improvement in SSA's programs, operations and management
by proactively seeking new ways to prevent and deter fraud, waste and abuse.
We commit to integrity and excellence by supporting an environment that provides
a valuable public service while encouraging employee development and retention
and fostering diversity and innovation.

MEMORANDUM

Date: September 11, 1008

To: The Commissioner

From: Inspector General

Subject: Controls over the Social Security Administration's Transit Subsidy
Program (A-02-08-18050)

OBJECTIVE

Our objectives were to (1) determine whether the Social Security Administration's
(SSA) Transit Subsidy Program policies and procedures were in compliance with
applicable laws, regulations and policies; (2) verify employee compliance with
the Program's participation requirements; and (3) ensure the appropriate internal
controls were in place and operating as intended.

BACKGROUND

The Federal Employees Clean Air Incentives Act, designed to improve air quality,
reduce traffic congestion, and expand commuting alternatives, provides for the
establishment of programs to encourage Federal employees to commute by means
other than single-occupancy motor vehicles. Pursuant to this Act, the Federal
transit benefits programs were established by Presidential Executive Order,
". . . to reduce Federal employees' contribution to traffic congestion
and air pollution and to expand their commuting alternatives." The Executive
Order required that all Federal agencies implement a transportation fringe-benefit
program no later than October 1, 2000.

SSA has two Transit Subsidy Programs for employees who use mass transportation:
the Mass Transportation Subsidy Program (MTSP), for which most employees are
eligible, and the National Capital Region Transit Subsidy Program (NCRTSP),
which is offered only to employees who work in Washington, D.C., and its suburbs.

Transit Subsidy Program Participant Responsibilities

To be eligible for the Transit Subsidy Programs, SSA employees must currently
use, or agree to use, mass transportation or a commuter highway vehicle such
as a vanpool to commute to and/or from work on a regular basis. Regular monthly
use does not necessarily mean every day of the work week; an employee, for example,
might regularly take mass transit 3 days a week and still be eligible for a
monthly subsidy. However, regular use does not include periodic or sporadic
use of mass transportation. The employee's monthly transit expenses must at
least equal the amount of the subsidy received.

Employees must use the transit subsidies for their own transportation costs
to and/or from work and must relinquish any parking passes for a reserved, assigned,
or car pool space or a parking subsidy issued by SSA or any other Federal agency,
before receipt of the transit subsidy. Also, employees must report changes to
actual expenses, office assignment, transportation mode, or home address and
must return unused subsidies to the Agency. Subsidies can only be used for the
month for which they are received and may not be used for more than 1 month's
subsidy at a time. Failure to abide by the transit program requirements, including
providing false or fraudulent information to obtain transit benefits, may be
grounds for disciplinary action up to and including dismissal, along with civil
and criminal penalties and other criminal action

To receive the transit subsidy, SSA employees must complete a Transit Subsidy
Application and Expense Worksheet, which details the employee's transportation
costs. Supervisors review and sign the Applications and Worksheets to ensure
they are legible, accurately completed and include the employee's signature.

Transit Subsidy Program Management

SSA's National Transit Coordinator (NTC) located at SSA's Headquarters in Baltimore,
Maryland, coordinates and oversees the administration of the Agency's Transit
Subsidy Programs nationwide, working primarily through Regional/Component Transit
Coordinators (RTC). The NTC also serves as the primary liaison with the Department
of Transportation (DOT). SSA contracted with DOT to purchase and distribute
the transit subsidies to SSA's employees. Lastly, Headquarters maintains the
SSA Transit Database System, with input from the RTCs and local transit coordinators,
which includes data for every SSA employee who is or was a Transit Subsidy Program
participant in either the MTSP or NCRTSP.

The RTCs coordinate the transit programs for all eligible employees who are
serviced by the RTC's Servicing Personnel Office. They provide the transit subsidies
to the participants in their region or component through local transit coordinators.
The subsidies are issued as transit vouchers, which look like debit cards, or
paper vouchers, which look like paper checks. DOT contracts with vendors to
produce and mail the cards and/or checks to SSA's RTCs.

Each card and check holds a specific dollar amount. Each participant is provided,
generally quarterly, enough cards or checks to equal the amount of transit subsidies
for which they are eligible for the upcoming quarter. When participants are
provided their allotment of cards or checks, they must sign a sheet acknowledging
receipt of the subsidy and affirming their information, including their transportation
costs, has not changed.

Report on Government-wide Transit Subsidy Misuse

On April 24, 2007, the Government Accountability Office (GAO) issued a report
that detailed instances of fraud and abuse of transit subsidies by Federal employees.
Examples of the abuse uncovered by GAO included an employee who drove to work,
parked for free in agency-provided parking, and still collected $105 per month
in transit subsidy vouchers, most of which he sold on the Internet. Other Federal
employees were also selling their benefits on the Internet. Additionally, some
former Federal employees continued receiving transit benefits after they separated
from their agencies.

In May 2007, the Office of Management and Budget (OMB) requested that all Federal
agencies implement specific internal controls to preserve the transit program's
benefits while eliminating the opportunity for fraud, waste, and abuse. The
internal controls requested by OMB included a breakdown of commuting costs for
each applicant and independent verification of eligibility, as well as checking
applicants against parking benefit records and including steps to ensure individuals
are removed from the benefits program when they leave the Agency's employment.

SSA stated in a June 26, 2007 response to OMB's May 2007 memorandum that it
was in compliance with all but one of the internal controls OMB requested. SSA
explained that it would modify its procedures to address the one outstanding
control request by OMB-a process to ensure that employees leaving employment
at SSA were removed from the Transit Subsidy Program.

We reviewed the procedures and internal controls SSA created for the two Transit
Subsidy Programs. Specifically, we determined whether the internal controls
required by OMB for Transit Subsidy Programs were established and working as
intended. To accomplish this objective, we reviewed a sample of 50 transit subsidy
participants from the population of 11,335 nation-wide MTSP and NCRTSP participants
who received subsidies totaling over $7 million between August 1, 2006 and July
31, 2007. We reviewed the completeness and accuracy of the participants' Transit
Subsidy Applications, Expense Worksheets, and Revocation Forms, if applicable.
We reviewed the employees' leave use and whether they had a change of duty station
during our audit period to ensure they met eligibility requirements. We also
reviewed whether these employees were using Government-provided parking while
receiving transit subsidies. Lastly, we compared the entire database of 11,335
participants to SSA personnel data to determine whether the Transit Subsidy
Program participants were in fact SSA employees and eligible for the subsidies
they received when they received them.

RESULTS OF REVIEW

We found SSA's Transit Subsidy Programs were designed in accordance with Executive
Order 13150, and the Agency's related procedures addressed the internal controls
requested by OMB. While we identified some errors and omissions in employees'
Transit Subsidy Applications and Expense Worksheets, generally the employees
we reviewed were eligible for the subsidies they received, completed the necessary
documentation detailing their transportation expenses, and had their Applications
and Expense Worksheets reviewed by their supervisors.

While SSA addressed the controls requested by OMB, some improvements to the
Transit Subsidy Programs are possible. A few of the Transit Subsidy Applications
and Expense Worksheets we reviewed did not have the appropriate signatures,
and we identified 34 Transit Subsidy Program participants who received transit
subsidies they were not entitled to and did not return. Also, SSA was unable
to document that all transit subsidy participants were routinely compared to
Agency parking records to ensure participants were not using a private vehicle
to commute to work, rather than mass transportation.

Lastly, while SSA had the controls requested by OMB in place at the time of
our audit, there was an inherent risk of misuse in the Transit Subsidy Program
because some vulnerabilities are outside the scope of the Agency's span of control-especially
as it relates to subsidy recipients who continue to drive or carpool and use
private parking services. The Agency does not have access to the data it would
need to identify participants parking off government property and/or in private
parking lots. Accordingly, the Agency has a limited ability to implement detection
controls. However, opportunities exist to implement complementary controls,
such as preventative and/or deterrent controls. Generally these controls include
the employee acknowledging that violation of the rules will result in certain
penalties or disciplinary action.

TRANSIT SUBSIDY PROGRAM INTERNAL CONTROLS

Transit Subsidy Documentation

In reviewing the Transit Subsidy Applications and Worksheets, we identified
17 documents that were completed but lacked the signatures of the participants
and/or supervisors. In two of these cases, neither the participant nor supervisor
signed required documents. Eight documents were missing the supervisor's signature,
and seven were missing the employee's signature. We also found one participant
made some minor calculation errors on his Expense Worksheet that did not affect
the transit benefit amount received since the participant's actual costs were
well over the maximum benefit amount provided by SSA.

Government-Provided Parking Privileges

OMB requested that all agencies check Transit Subsidy Program participants
against parking benefit records. Generally, participants should be checked against
parking records since the use of Government-provided parking, subsidized or
freely provided, would indicate that a Transit Subsidy Program participant was
using a private vehicle to commute to work, rather than mass transportation.
SSA reported that the 50 participants we reviewed did not use parking provided
by the Agency. However, not all of the RTCs maintained evidence documenting
that routine reviews occurred.

While we requested evidence from all the RTCs that documented the steps they
completed to ensure the 50 participants were not also receiving parking privileges,
we only received such evidence for the participants who worked at SSA's Headquarters
in Baltimore and in two other locations. The NTC at Headquarters reported that
the Agency maintained a database of employees with parking passes at the site
and regularly compared transit subsidy participants' names to these records.
The names of Headquarters employees applying for or renewing their parking passes
were checked against the Transit Database System to ensure they were not also
receiving transit subsidies. Records were maintained, and shared with us, that
documented the checks were being completed routinely. We reviewed the documentation
and concluded that SSA's Headquarters had a control in place to ensure Headquarters
employees participating in the Transit Subsidy Programs were not also receiving
Agency-provided parking privileges. A similar process of comparing a list of
current transit subsidy participants with available parking lists was in place
at two other locations. We received and reviewed supporting documents to conclude
that the transit subsidy participants were not receiving Government sponsored
parking benefits.

While most RTCs outside of Headquarters did not provide us evidence, they reported
that they verified whether participants were receiving parking privileges in
several different ways. For example, they reported checking transit subsidy
applications against daily parking logs or relying on their personal knowledge
of employees' commutes. Some locations provided preferred parking on a rotational
basis, and RTCs for these locations reported taking transit subsidy participants
off the preferred parking rotation. Still, these RTCs were unable to provide
documentation detailing these activities. The lack of documentation provided
prevented us from testing or confirming the RTC's assertions that the participants
were not receiving parking privileges.

Other Controls

The TransitChek cards or paper vouchers provided to Transit Subsidy Program
participants have some built-in controls to help ensure the cards are only used
for appropriate transportation expenses. For example, the debit cards are programmed
to be denied if the vendor attempting to use the card for payment is not a legitimate
transportation vendor. The paper vouchers include the statement, "Pay to
the order of a participating transit operator only." Per this statement,
only participating transit operators are eligible to deposit the vouchers for
reimbursement into their bank accounts. Also, the paper vouchers cannot be cashed,
nor can cash change be given if the entire amount of the voucher is not used.

Per DOT staff, the control on the debit cards can be manually passed if a vendor
manually forces the transaction through its debit machine, as opposed to swiping
the debit card through it. The vendor who produces the card for DOT receives
a report when a card is manually processed to elude the built-in control, though
DOT had never requested to review these reports. Since DOT does not receive
the reports, SSA is also not receiving the reports related to any ineligible
manual transactions for cards provided to SSA Transit Subsidy Program participants.

Lastly, the controls built in the debit cards do not prevent a participant
in one region from using a debit card in another region. A participant who works
in the New York City metropolitan region could use his debit card in the Chicago
metropolitan region (or pass it to someone to use in a different region). As
long as the card was used for a valid transportation related expense, the transaction
would not be denied, nor would a report be generated with the vendor.

TRANSIT SUBSIDY REMITTANCES

In our review of 50 participants, we identified 1 person who received 1 month
of transit benefit ($60) to which he was not entitled. The employee, now retired,
had received a transit subsidy for a month during which he was on leave. We
found no indication this subsidy was returned.

Having identified an individual who received subsidies he was not entitled
to within the 50 cases we reviewed, we completed a broader test to determine
whether ineligible individuals received transit subsidies from SSA. We compared
the 11,335 employees in SSA's Transit Subsidy Programs between August 1, 2006
and July 31, 2007 to a list of all of SSA's employees. From this data match,
we identified 34 Transit Subsidy Program participants who received a total of
$3,530 in subsidies they were not entitled to and did not return. These participants
were generally provided benefits for an upcoming quarter, or 3 month's worth
of subsidies, but they separated from the Agency before the end of the quarter
and did not return the balance of the allowance. Some of the participants were
temporary employees, typically summer interns, who received the entire 3-month
benefit but were only with the Agency, and entitled to the benefit, for 2 months.

SSA had implemented a change to its procedures at the end of our audit period
to address this issue. In response to OMB's request for controls in the program,
SSA added steps to its Form SSA 2324, Clearance Of Employees For Separation
Or Transfer, to remove departing employees from the Transit Subsidy Program
and return any transit subsidy funds, if applicable. SSA also updated its Transit
Subsidy Program website and documentation, including the SSA Transit Subsidy
Program Coordinator's Handbook, to include the procedures related to departing
employees. Supervisors are instructed to check with the RTCs to verify that
departing employees have returned any unused transit subsidies or have reimbursed
the Agency for them. If not, the employee must be referred to the Office of
Finance to eliminate the debt.

TRANSIT SUBSIDY PROGRAM RISKS

Even though SSA has a number of controls in place to ensure transit subsidies
are appropriately used by eligible participants, a risk of misuse still exists
in the programs. For example, while participants may assert they are commuting
to work on public transportation paid for with the subsidy, they may not actually
do so for some or all of the days for which they were provided a transit subsidy.
Also, a participant can accept the transit subsidy and drive or be driven to
work. This may be more easily done in larger offices and/or larger metropolitan
areas where supervisors may not witness how participants actually get to work.
While SSA may compare participants to lists of those who receive Agency-provided
parking, SSA cannot match participants to those who drive and park on local
streets or those who use private parking lots near their places of work.

A recent investigation by our Office of Investigations (OI) demonstrated the
risk still inherent in the Transit Subsidy Program. As a result of a complaint
brought to the OIG by an individual who witnessed transit subsidy participants
using private garage services, OI initiated an investigation. It is estimated
that 105 of the 342 transit subsidy participants at the location in question
had monthly parking garage contracts with the privately owned and managed parking
garage at the worksite. It appears that these employees were driving their private
cars to work and not using the subsidies for public transportation needed to
get to and from work, so they were not entitled to receive a transit subsidy.

Five of the 105 employees were interviewed by OI and admitted to knowingly
abusing their transit subsidies. These employees reported saving the transit
subsidies they were provided for possible future use, using them on occasion,
or giving the subsidy away to family members. While the parking garage was located
in the same building as the SSA office, the garage was privately managed, and
SSA did not have access to its records.
This investigation demonstrated employee noncompliance with the program requirements,
as well as the Program's inherent susceptibility to misuse. Much of the data
that would inform the Agency of misuse is outside SSA's control. To that end,
the Agency has a limited ability to implement detection controls. However, there
are options for implementing complementary controls such as preventative/deterrent
controls. Generally, these controls include the employee acknowledging that
violation of the rules will result in certain penalties or disciplinary action.

In reviewing the Agency's Transit Subsidy Program, we found limited language
related to prescribed disciplinary action for violating program rules. The Transit
Subsidy Application contains a section entitled "Certification by Applicant"
above the applicant's signature line. This section states,

By signing and submitting this application, I certify that I am an eligible
SSA employee and the information I have furnished is accurate and truthful to
the best of my knowledge and belief. I agree to abide by the rules and requirements
of the Mass Transportation Subsidy Program and notify my immediate supervisor
if any information supplied above should change.

Verified falsification of an application or failure to report a change in eligibility
will result in immediate termination from the Program and may subject the employee
to disciplinary action.

Upon receipt, voucher/fare media become the property and responsibility of
the authorized participant and can only be used by the participant. SSA will
not provide a refund, replacement, redemption, or exchange of any kind for any
reason or circumstance. Unused vouchers must be returned. It they cannot be
returned, the Agency must be reimbursed. Debt collection procedures will be
initiated against those employees who do not return unused vouchers or reimburse
the Agency.

The application does not include a statement acknowledging the consequences
of misusing transit subsidies. Additionally, SSA's Transit Coordinator's Handbook
does not specifically define transit "misuse" and has limited language
on the consequences of "misuse." Specifically, the Employee Responsibility
Letter, which is included as an appendix in the Transit Coordinator's Handbook,
states "Any misuse of your transit benefits may be grounds for disciplinary
action up to and including dismissal, along with civil and criminal penalties
and other criminal action." The Transit Coordinators' Handbook does not
mandate that employees receive, or acknowledge receipt of, this letter and it
does not include a signature line for employees.

SSA staff reported that disciplinary actions for the misuse of Transit Subsidy
Program benefits are administered locally and are based upon supervisors' discretion
depending on the circumstances. In an environment with an inherent risk of misuse,
the absence of clear disciplinary guidelines and procedures further impairs
the Agency's ability to deter such behavior.

CONCLUSION AND RECOMMENDATIONS

While SSA had many controls in place, we found that some participants and supervisors
did not sign required documentation, and SSA reported using various methods
to determine whether participants were also receiving Agency-provided parking
subsidies. Also, we identified some individuals who received subsidies for which
they were not entitled. However, SSA implemented a change to its procedures
at the end of our audit period to help ensure employees leaving the Agency returned
unused portions of transit subsidies. Lastly, we determined that even with the
controls SSA has in place, there is an inherent risk of misuse in the program.
The data that would inform the Agency of violations is often outside the control
of the Agency. To that end, the Agency has limited ability to detect such violations
and it must take the necessary steps to ensure that preventative controls are
in place to deter such activities, and, once violations are detected, appropriate
corrective action taken. Based on these findings, we recommend that SSA:

1. Provide annual reminders to employees and to supervisors on the responsibilities
under the transit subsidy benefit programs, including the requirement for supervisors
to review and sign all appropriate documentation.

2. Develop standardized procedures to ensure transit subsidy participants do
not also use Agency-provided parking privileges.

4. Confirm and retrieve transit subsidy funds due from the 34 individuals identified
in this report.

5. Periodically match the database of Transit Subsidy Program participants
to personnel records to ensure that departing employees return subsidies for
which they are ineligible.

6. Develop and implement appropriate procedures that define transit subsidy
misuse and corresponding disciplinary actions that will be taken if misuse occurs.

7. Update the Transit Subsidy Application's "Certification by Applicant"
section to include an acknowledgement that misuse of transit subsidies will
result in the disciplinary action developed to implement the previous recommendation.

AGENCY COMMENTS

The agency agreed with all of our recommendations. The Agency provided a technical
comment, which was incorporated into the report. The Agency's comments are included
in Appendix C.

Compared SSA's transit policies and written procedures with Executive Order
13150 and with Department of Transportation guidance for Transit Subsidy Programs.

Reviewed and confirmed that the participation requirements as indicated by
the Office of Management and Budget were met.

Obtained a data file of SSA transit data containing records for 11,335 participants
in the Mass Transportation Subsidy Program or the National Capital Region Transit
Subsidy Program between August 1, 2006 and July 31, 2007.

Compared the data file of Transit Subsidy Program participants with the available
human resource personnel file of all SSA employees.

Reviewed a random sample of 50 employee transit applications, expense worksheets,
time sheets and personnel data to determine compliance with participation requirements.
Also, we requested documentation of the data used and/or tests completed by
SSA to ensure the 50 employees were also not receiving Government-provided parking
privileges. While SSA provided documentation demonstrating that such tests occurred
for employees at its Headquarters complex in Baltimore and two other locations,
it did not provide evidence for employees who worked at most other locations.
Accordingly, we were unable to independently verify if Transit Subsidy Program
participants who worked at most locations were properly excluded from Government-provided
parking.

Determined whether employees received subsidies for which they were not eligible.

Reviewed the Office of the Inspector General, Office of Investigations' Report
of Investigation related to transit subsidy violations.

Reviewed SSA's controls and the results of a recent Office of Investigations'
investigation to identify an inherent risk of misuse in the Transit Subsidy
Program. While SSA had controls in place over the Program, the controls did
not address and could not prevent employees from accepting transit subsidies
and also routinely commuting to work in a private vehicle. While SSA's controls
were established to identify employees receiving transit subsidies and parking
privileges at the same time, which would indicate the use of a private vehicle,
SSA did not have access to records of private parking services and could not
systematically identify those who drove to work and parked near the office (but
off Agency property). While the results of a recent Office of Investigations'
investigation identified this condition at one locale, the extent of this type
of misuse is unknown. We were unable to develop tests that would quantify the
extent of this type of misuse.

We found data used for this audit were sufficiently reliable to meet our objectives.
The entities audited were the Offices of Human Resources and Budget, Finance
and Management. We performed our work at the New York Audit Division, New York,
New York, from March through May 2008. We conducted our audit in accordance
with generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence
to provide a reasonable basis for our findings and conclusions based on our
audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.

Appendix C
Agency Comments

SOCIAL SECURITY

MEMORANDUM

Date: August 27, 2008
To: Patrick P. O'Carroll, Jr.
Inspector General

From: David V. Foster
Executive Counselor to the Commissioner

Subject: Office of the Inspector General (OIG) Draft Report, "Controls
over the Social Security Administration's Transit Subsidy Program" (A-02-08-18050)-INFORMATION

We appreciate OIG's efforts in conducting this review. Our response to the
report findings and recommendations is attached.

Please let me know if we can be of further assistance. Please direct staff
inquiries to Ms. Candace Skurnik, Director, Audit Management and Liaison Staff,
at extension 54636.

SSA Response

COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL (OIG) DRAFT REPORT, "CONTROLS
OVER THE SOCIAL SECURITY ADMINISTRATION'S (SSA) TRANSIT SUBSIDY PROGRAM"
(A-02-08-18050)

Thank you for the opportunity to review and comment on the draft report. We
concur with the proposed draft. We believe that the report correctly identifies
possible areas for abuse and believe the recommendations will improve and strengthen
the integrity of our Transit Subsidy Program. We fully support the efforts to
control and eliminate incidences of abuse in this program. While several transit
coordinators at the component and regional levels have procedures in place,
we recognize the need for improvement, consistency, and enforcement. Our responses
to the specific recommendations are as follows.

Recommendation 1

Provide annual reminders to employees and to supervisors on the responsibilities
under the transit subsidy benefit programs, including the requirement for supervisors
to review and sign all appropriate documentation.

Comment

We agree. We will develop and distribute an agency-wide annual reminder for
participants and supervisors by November 2008. While we have completed this
at the component level, we will ensure that all participants receive one reminder
each year. For example, the Office of Disability Adjudication and Review (ODAR),
has implemented this recommendation with respect to all of its eligible employees
and their supervisors. On May 28, 2008, ODAR released a memorandum to employees
and a separate memorandum to supervisors as a reminder of the employee responsibilities
under the transit subsidy benefit program. Additionally, ODAR is planning to
provide biannual reminders in early November and May of each year.

Recommendation 2

Develop standardized procedures to ensure transit subsidy participants do not
also use agency-provided parking privileges.

Comment

We agree, where parking privileges are provided. We will develop procedures,
in collaboration with the regional transit coordinators, to ensure participants
do not use agency-provided parking privileges. We plan to implement these procedures
by December 2008.
Recommendation 3

Coordinate with the Department of Transportation (DOT) to receive vendor reports
related to ineligible manual transactions for TransitChek cards provided to
SSA employees.

Comment

We agree. We contacted DOT several months ago and again on August 1, 2008,
to request that it provide us with the vendor reports relating to ineligible
manual transactions for TransitChek cards. We expect that it will provide us
with the requested information.

Recommendation 4

Confirm and retrieve transit subsidy funds due from the 34 individuals identified
in this report.

Comment

We agree. We have confirmed the debts. Of the 34 employees who owe money to
the agency, only two are active employees. We will work with the transit coordinators
to retrieve the funds from these two employees. Information on the 32 separated
employees will be provided to the Office of Finance by September 2008, so it
may invoke the agency's administrative debt collection procedures. We will consider
the dollar thresholds included in the procedures to determine how actively to
pursue the debt.

Recommendation 5

Periodically match the database of Transit Subsidy Program participants to
personnel records to ensure that departing employees return subsidies for which
they are ineligible.

Comment

We agree. Several of our components have measures in place to ensure that we
remove separating/transferring employees from this program. However, we will
develop and implement agency-wide procedures to ensure that consistent action
is taken to address this matter. We plan to run a periodic report that matches
data in the agency's personnel records with data in our transit subsidy database
starting in October 2008.

Recommendation 6

Develop and implement appropriate procedures that define transit subsidy misuse
and corresponding disciplinary actions that will be taken if misuse occurs.

Comment

We agree. We will develop and implement the appropriate guidance and procedures
that define transit subsidy misuse and the correlating disciplinary action.
We will implement guidance and procedures by December 2008.

Recommendation 7

Update the Transit Subsidy Application's "Certification by Applicant"
section to include an acknowledgement that misuse of transit subsidies will
result in the disciplinary action developed to implement the previous recommendation.

Comment

We agree. We will update the application to include an acknowledgement that
the misuse of transit subsidies may result in disciplinary action. This update
will be in place by September 2008.

[In addition to the information listed above, SSA also provided technical comments
which have been addressed, where appropriate, in this report.]

For additional copies of this report, please visit our web site at www.socialsecurity.gov/oig
or contact the Office of the Inspector General's Public Affairs Staff Assistant
at (410) 965-4518. Refer to Common Identification Number A-02-08-18050.

Overview of the Office of the Inspector General
The Office of the Inspector General (OIG) is comprised of an Office of Audit
(OA), Office of Investigations (OI), Office of the Counsel to the Inspector
General (OCIG), Office of External Relations (OER), and Office of Technology
and Resource Management (OTRM). To ensure compliance with policies and procedures,
internal controls, and professional standards, the OIG also has a comprehensive
Professional Responsibility and Quality Assurance program.

Office of Audit
OA conducts financial and performance audits of the Social Security Administration's
(SSA) programs and operations and makes recommendations to ensure program objectives
are achieved effectively and efficiently. Financial audits assess whether SSA's
financial statements fairly present SSA's financial position, results of operations,
and cash flow. Performance audits review the economy, efficiency, and effectiveness
of SSA's programs and operations. OA also conducts short-term management reviews
and program evaluations on issues of concern to SSA, Congress, and the general
public.

Office of Investigations
OI conducts investigations related to fraud, waste, abuse, and mismanagement
in SSA programs and operations. This includes wrongdoing by applicants, beneficiaries,
contractors, third parties, or SSA employees performing their official duties.
This office serves as liaison to the Department of Justice on all matters relating
to the investigation of SSA programs and personnel. OI also conducts joint investigations
with other Federal, State, and local law enforcement agencies.

Office of the Counsel to the Inspector General
OCIG provides independent legal advice and counsel to the IG on various matters,
including statutes, regulations, legislation, and policy directives. OCIG also
advises the IG on investigative procedures and techniques, as well as on legal
implications and conclusions to be drawn from audit and investigative material.
Also, OCIG administers the Civil Monetary Penalty program.

Office of External Relations
OER manages OIG's external and public affairs programs, and serves as the principal
advisor on news releases and in providing information to the various news reporting
services. OER develops OIG's media and public information policies, directs
OIG's external and public affairs programs, and serves as the primary contact
for those seeking information about OIG. OER prepares OIG publications, speeches,
and presentations to internal and external organizations, and responds to Congressional
correspondence.

Office of Technology and Resource Management
OTRM supports OIG by providing information management and systems security.
OTRM also coordinates OIG's budget, procurement, telecommunications, facilities,
and human resources. In addition, OTRM is the focal point for OIG's strategic
planning function, and the development and monitoring of performance measures.
In addition, OTRM receives and assigns for action allegations of criminal and
administrative violations of Social Security laws, identifies fugitives receiving
benefit payments from SSA, and provides technological assistance to investigations.